T. M. E. v. Strope, 476 P.3d 972

Petitioner (senior pastor) leased church space to respondent, who ran a school; petitioner gave respondent 14 days to vacate after terminating the lease.
On August 7 (during the 14-day period), petitioner approached respondent about removal of school property; respondent said there was “a special place in hell for pastors like you” and allegedly poked a finger in his chest.
On August 21, respondent and her father confronted petitioner at the church driveway; respondent pushed past her father, grazed petitioner with her fingertips, ripped up the notice, threw keys that bounced off petitioner’s face, and yelled expletives; petitioner said he would call 9-1-1 and they left.
Petitioner obtained a temporary stalking protective order (SPO) based on the August 7 and August 21 contacts; after a hearing the trial court found petitioner credible and issued a permanent SPO.
Respondent appealed, arguing (inter alia) insufficient evidence that there were two qualifying "unwanted contacts" and that petitioner’s subjective alarm was objectively reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Aug. 7 contact (finger poke + speech) qualified as an "unwanted contact" that gave rise to objectively reasonable alarm	Petitioner: the poke and hostile words were unwanted and alarmed him	Respondent: the contact occurred while she had permission to be on church property during the move-out period; conduct was nonthreatening context and amounted to anger/harangue, not a threat	Court: The record lacks evidence that a reasonable person in petitioner’s situation would have perceived a threat of physical injury; Aug. 7 contact did not qualify
Whether there were legally sufficient "repeated" unwanted contacts to support an SPO	Petitioner: both Aug. 7 and Aug. 21 incidents together establish repeated unwanted contacts	Respondent: without Aug. 7 qualifying, only one qualifying incident remains	Court: Because Aug. 7 did not qualify, petitioner failed to prove two or more qualifying contacts; SPO reversed

Miller v. Hoefer, 269 Or. App. 218 (2015) (speech alone does not qualify as a threatening contact for an SPO unless it instills fear of imminent serious violence)
King v. W.T.F., 276 Or. App. 533 (2016) (appellate sufficiency review of SPO evidence viewed in light most favorable to trial court)
Brown v. Roach, 249 Or. App. 579 (2012) ("danger" means a threat of physical injury, not mere annoyance)
Greenwade v. Tepper, 285 Or. App. 646 (2017) (no objectively reasonable alarm where incident showed no endangerment or future risk)
Reitz v. Erazo, 248 Or. App. 700 (2012) (contextually relevant speech may inform evaluation of non‑speech contacts)
Van Buskirk v. Ryan, 233 Or. App. 170 (2010) (hyperbole and rhetorical excess generally do not warrant an SPO)
Huber v. Landolt, 267 Or. App. 753 (2014) (legislature did not authorize SPOs for merely unsettling or unpleasant conduct)
Valerio v. Valerio, 224 Or. App. 265 (2009) (SPO statute requires repeated contacts; if one incident fails to qualify, analysis of lone remaining incident is unnecessary)